Rulemaking - Chapter 173-446 WAC, Climate Commitment Act Program
THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, JOANNE KELLY 7051 35th Ave NESeattle, WA 98115
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Kimberly Teraberry 532 18th Ave ESeattle, WA 98112
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, kathy grieves 7709 W Vía Del SolPeoria, AZ 85383
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Joann Terranova 1620 Woodard Ave NWOlympia, WA 98502
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Laura Toussaint 14301 SE 21st StVancouver, WA 98683
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Jeannie Finlay-Kochanowski 229 Majestic DrToledo, OH 43608
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Barbara Harper 13535 Agua DulceCastroville, CA 95012
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Kathleen O'Connell 5360 Singleton StIndianapolis, IN 46227
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Cheryl Speer 410 SW Park StCamas, WA 98607
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Julia Reed 1 Ward StSeattle, WA 98109
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Fiona Stefanik 5315 NE 60th AvePortland, OR 97218
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Greg Stawinoga 1247 E 168th PlSouth Holland, IL 60473
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Lynn Rabenstein 201 N Section StBurlington, WA 98233
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Cathy Anderson 432 11th Ave SWCambridge, MN 55008
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Kelly Caffrey 117 Roosevelt BlvdSayreville, NJ 08859
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Julia Kladnik 15 5th StTonasket, WA 98855
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Dorothy Strassner 6121 NE 175th StKenmore, WA 98028
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Scott Merrell PO Box 2153Thompson Falls, MT 59873
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Sandra Ciske 1717 Sunset Ave SWSeattle, WA 98116
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, J K 15120 Starr Rd SEOlalla, WA 98359
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Jerry Rivers 8 Gombert PlRoosevelt, NY 11575
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Susan Catelli-Hill 518 Sweet Hollow RdMelville, NY 11747
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Sandra Garcia 33-37 New York AveNewark, NJ 07105
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Laura Zerr 33916 186th Ave SEAuburn, WA 98092
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Steve Berman 2424 Spaulding AveBerkeley, CA 94703
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Susie Cassens 1717 Orange AveFort Pierce, FL 34950
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Chris Riesch 29 Spruce StPawling, NY 12564
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Willard Westre 15704 SE 44 StBellevue, WA 98006
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Karen Fortier 28129 Florence Acres RdMonroe, WA 98272
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Thomas Gates 33207 11th Ave SWFederal Way, WA 98023
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Jewell Batway 11301 E Jupiter DrApache Junction, AZ 85120
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Dean McBee 12546 33rd Ave NESeattle, WA 98125
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Ilya Speranza 379 Decatur StBrooklyn, NY 11233
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Bill Justis 6345 Cedar Flats Rd SWOlympia, WA 98512
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Lorraine Brabham 932 Bloomfield StHoboken, NJ 07030
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Lisa Richmond 3318 Hunter Blvd SSeattle, WA 98144
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, David Randall 805 W 29th AveSpokane, WA 99203
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Dear Mr. Grice, WA ...↓Dept. of Ecology:Thank you for the opportunity to comment on the Climate Commitment Act.Overall, I support the general direction of the proposed rule but urge Ecology to strengthen it in the ways that the WA Environmental Council has enumerated; however I would like you to consider some new ideas.We are always looking for renewable energy sources, yet we seem never to address the need to reduce energy use; instead, we continue to permit entities that compete with citizens and small businesses for WA State's finite energy sources; therefore, I urge the Dept. of Ecology to prevent further approval of energy hogging industries such as computer cloud services or any blockchain enterprises regulated by the state. These industries should not be treated as other corporations because of the massive energy use required to operate. Such services should have to pay much more perhaps modeling the cost on the idea of escalating rates for water usage. Allowing such energy hogs to pay the same as businesses raises the cost of energy for everyone, contributing to inequitable climate consequences, especially for citizens.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you,Alicelia Warren2122 Bridgeport Way WUniversity Place WA 98466Thank you, alicelia warren 2122 Bridgeport Way WUniversity Place, WA 98466
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Jesse Mallory 4007 S Underwood PlKennewick, WA 99337
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Mel GOULD 1395 Poplar DrMedford, OR 97504
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program.The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Virginia Davis 17721 NE 156th StWoodinville, WA 98072
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, MJ Stojak 2411 NW 195th PlShoreline, WA 98177
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Andrea Jordan 13975 East 35th St SIndependence, MO 64055
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, William Sneiderwine 14901 SE Sunpark DrVancouver, WA 98683
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Charles Alexander 1810 York RdLutherville-timonium, MD 21093
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Nancy Gleim 313 Charlotte WayVancouver, WA 98664
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Paul Roberts 1519 Federal Ave ESeattle, WA 98102
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Erika Thorsen 904 Newell StBellingham, WA 98225
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Aminah Lamb-McMurray 14610 Cedar Grove Rd SEIssaquah, WA 98027
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, fay forman 355 8th AveNew York, NY 10001
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, John Staunton 205 E Fairview AveSouth Bend, IN 46614
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Steve Green 12719 Country Club PlBurlington, WA 98233
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Marco Pardi 2195 Sandown CtLawrenceville, GA 30043
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Heather Murawski 17929 W Spring Lake Dr SERenton, WA 98058
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, James Williams 9614 50th Pl WMukilteo, WA 98275
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Edward Whitesell 816 Plymouth St SWOlympia, WA 98502
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Mike O'Shea 6620 151st Ave NERedmond, WA 98052
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Jim Haley 35399 Ridge Rte RdCastaic, CA 91384
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Diane Basile 7 Evert StHuntington Station, NY 11746
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Anita Scheunemann 6316 199th Loop SWRochester, WA 98579
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Star Scott 140 Winterwood DrWinterville, GA 30683
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Ronald Kaufman 5015 S Woodfield LnSpokane, WA 99223
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Cathie kwasneski 201 3rd AveMonroe, WI 53566
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Climate change, like numerous other issues (gun safety, immigration reform, prison reform, education reform, short-term lending regulation, healthcare reform, banking regulation, opioid regulation) remains a vexing problem primarily due to corporations' ability to curry favor with elected officials. The corrupting influence of money in our political system is undermining our democratic traditions and discouraging Americans from voting and/or running for office. This ominous development may well end our experiment in representative democracy unless we alter this decades-long trend. For the sake of the republic, we must amend the US Constitution to state that corporations are not people (and do not have constitutional rights) and money is not speech (and thus can be regulated by state and/or federal campaign finance laws). Short of accomplishing this, no other reform of significance will be achieved. The moneyed interests will turn any reform to their benefit, often at the expense of the nation as a whole.Thank you, James Klein 3501 Monterrey StCorpus Christi, TX 78411
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Kirstin Eventyr 2805 Gull Harbor Rd NEOlympia, WA 98506
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Gillian Stewart 1421 21st StPort Townsend, WA 98368
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. I am a biologist, recently retired biology instructor, and long-time resident of WA State. I stand with Washington Conservation Voters' position, as articulated below, on this rule.The importance of strong climate action in WA State is even greater now, with the SCOTUS ruling that limits the power of the EPA to act on climate-altering emissions.The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Melinda Mueller 7704 16th Ave NWSeattle, WA 98117
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Julie Rodgers 8121 NE 141st StBothell, WA 98011
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, James Feit 2906 Jackman StPort Townsend, WA 98368
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Kristine Winnicki 257 Goat Farm RdChester, VT 05143
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Debra Rehn 5130 SE 30th AvePortland, OR 97202
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Kay Elmer 2830 NW Pine Cone DrIssaquah, WA 98027
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Diane Gordon 3011 78th Ave SEMercer Island, WA 98040
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Antoinette Bonsignore 12411 Totem Lake WayKirkland, WA 98034
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Christy Spear 16971 330th PlIsle, MN 56342
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Kathy Bradley 1220 Fredericksburg Dr SLugoff, SC 29078
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Thom Lufkin 212 21st Ave SEOlympia, WA 98501
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Alfred Ferraris 1340 Corona StPort Townsend, WA 98368
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Hilke Faber 3921 25th Ave SSeattle, WA 98108
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Raleigh Koritz 4505 Nathan Ln NPlymouth, MN 55442
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Sarah Bauman 695 Chuckanut Dr NBellingham, WA 98229
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Frederick Duhring 2845 13th Ave WSeattle, WA 98119
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Dianna MacLeod 3513 Wildes RdClinton, WA 98236
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Susan Schmidt 4282 State RdMedina, OH 44256
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Norman Baker 3789 Lost Mountain RdSequim, WA 98382
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Amy Henry 22 Perkins AveNorthampton, MA 01060
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives...The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Juanita Hull 5533 1200 WOgden, UT 84405
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Aisha Farhoud 4750 16th Ave NESeattle, WA 98105
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. Here in Washington we have The Climate Commitment Act, which is the strongest carbon pricing program in the country! I am optimistic about its potential to reduce carbon, boost the economy, and actively serve communities burdened with extreme environmental problems. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.Please insure that the program rules are maintained! it is essential that Ecology has the clear authority to act, that the responsibilities of covered entities are explicit and that the people of Washington are kept informed on this program, with opportunities to comment. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Kristin Blalack 1018 Central St NEOlympia, WA 98506
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Charles Favorite 16971 330th PlIsle, MN 56342
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives...The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Gary Hull 5533 1200 WOgden, UT 84405
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, John Thompson 4953 S Spinnaker DrFreeland, WA 98249
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, James Freeberg 823 Blackberry LnAshland, OR 97520
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Chad Evans 1928 SW Bay StPort Orchard, WA 98366
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of Washington’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, David Doering 1544 Polk StSan Francisco, CA 94109
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Grace Padelford 11807 100th Ave NEKirkland, WA 98034
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Patti Brent 13717 NW 2nd AveVancouver, WA 98685
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Eleanor Morris 150 E Peaceful PlGrapeview, WA 98546
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THIS EMAIL ORIGINATED FROM OUTSIDE THE WASHINGTON STATE EMAIL SYSTEM - Take caution not to open attachments or links unless you know the sender AND were expecting the attachment or the linkDear Mr. Joshua Grice WA Dept. of Ecology,Thank you for the o...↓pportunity to comment on this critical rule that will shape implementation of our state’s cap & invest program. The Climate Commitment Act is the strongest carbon pricing program in the country, and I am excited about its potential to reduce carbon, grow the economy, and invest in overburdened communities. The state legislature intentionally integrated environmental justice, tribal sovereignty, and tools to address environmental impacts into the structure of the law. I appreciate the work that Ecology has undertaken to translate this far-reaching statute and faithfully implement its directives.The program rules are important to get right so that Ecology has the clear authority to act, the responsibilities of covered entities are clear, and the people of Washington have clarity on this program. Overall, I support the general direction of the proposed rule and urge Ecology to strengthen it in the following ways:Overburdened communities and environmental harm:- Articulate Ecology’s responsibility to ensure the cap-and-invest program avoids negative impacts to overburdened communities and describe how information will be gathered and used to fulfill that responsibility.- Clarify Ecology’s role in evaluating impacts of all Emission-Intensive Trade-Exposed facilities (EITEs) on overburdened communities, regardless of when each facility becomes a covered entity.- Establish an explicit process to review impacts of program implementation on outcomes relative to overburdened communities, in order to inform Ecology’s mandatory reporting to the legislature required by RCW 70A.65.060(5). The rule must provide information sufficient to conduct a meaningful and thorough review. This process should be separate from the “Improving Air Quality in Overburdened Communities” initiative, be inclusive of the full range of overburdened communities as defined by the law, and focus on disparities of impacts across the entire program.Tribal Sovereignty:- Explicitly incorporate Ecology’s existing obligation to proactively engage and consult with federally recognized tribes.Information to enable review and accountability:- Require all covered entities to provide information about: a) their impacts to overburdened communities and to tribal lands and treaty rights; b) the chemicals and pollutants they process and/or manage; and c) if there are any violations under any permits they hold.- Provide guidance and establish reporting requirements for consumer-owned utilities on the use of the value of no cost allowances and engage with the UTC on its regulation of investor-owned utilities’ use of the value of no cost allowances. - Best available technology: Require EITEs applying for an upward adjustment of no cost allowances to submit information on any excessive environmental impacts of the fuels, processes, and equipment used by each facility. The rule should be clear that if the facility is found to create excessive environmental impacts, upward adjustments should be denied.- Establish requirements for Ecology to publicly share and document data being used to establish baseline information, subtotal baselines, and allocations. Environmental Justice Council:- Include explicit language describing how Ecology will engage with the Environmental Justice Council in the development, implementation, and evaluation of the full program.- Track information about the environmental and health impacts of all covered entities to inform Council review. Offsets:- Establish a process for future modification of offset protocols, including: 1) Adaptation of existing carbon offset protocols in response to lessons learned in California and Washington. For example, updating the existing Urban Forestry Protocol, which is not currently implementable, to provide benefits in urban communities hardest hit by facilities and pollution; and 2) Creation of new protocols to harness climate mitigation potential of other ecosystems and land uses, such as blue carbon or agriculture.- Provide mechanisms for aggregation of landowners who would otherwise face barriers to participation in carbon offsets—particularly Tribal Nations and small forest landowners— in order to maximize benefits to local communities, tribes, and land owners of all sizes.- Clarify the process for reducing offset limits in response to cumulative air pollution burden in overburdened communities, including how data will be gathered and shared.- It is critical that offset rules are guided by feedback from Tribal Nations, designed to facilitate participation of tribal nations, and support tribal sovereignty.I look forward to Ecology’s ongoing work to strengthen and finalize this rule as part of our state’s work to meet our climate goals in an equitable and just way.Thank you, Ed Taylor 50 Northridge TerraceMadison, WI 53704
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